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Kansas Exempts Specific Pharmaceutical Wastes from Hazardous Waste Regulations

Healthcare facilities in Kansas, including hospitals, clinics, pharmacies, physician’s offices, and outpatient care centers, can take advantage of new state guidance designed to ease the burden of pharmaceutical waste disposal for a limited group of pharmaceutical products. On August 29, 2012, the Kansas Department of Health and Environment (KDHE) issued a guidance document entitled “Regulation of Pharmaceuticals from Non-Exempt Generators of Hazardous Waste” that exempts four classes of pharmaceuticals from hazardous waste regulations if the healthcare facility satisfies certain conditions.

EPA to Issue Final Vapor Intrusion Guidance by the End of November 2012

Nearly 10 years to the day when EPA issued its Draft Guidance for Vapor Intrusion, EPA is poised to finalize its Final Vapor Intrusion Guidance on or before November 30, 2012.

EPA Aggressively Pursuing FIFRA Enforcement of Misbranded and Unregistered Pesticides in Region 4, Region 5, and Region 7

On September 7, 2012, EPA announced the largest ever criminal fine and civil penalty, a combined $12.5 million enforcement action, under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which regulates the manufacture, distribution, sale, and use of pesticides in the United States.

Regulators Develop Framework to Address the “Hidden Costs” of Institutional Controls Associated with Remedial Site Cleanups

Companies undertaking remedial cleanups at Brownfield and CERCLA sites should anticipate increased cost estimates for long-term stewardship and oversight in response to a recently issued report by the Association of State and Territorial Solid Waste Management Officials describing fundamental flaws in the current cost estimation methodology associated with long-term stewardship.

DOT Evaluating New HazMat Regulations for Reverse Logistics of Retail and Consumer Products

Companies involved in the shipment, transportation, distribution, and logistics of consumer products and retail items that contain “hazardous materials” (HazMat) – as regulated by the U.S. Department of Transportation (DOT) – may soon face new requirements from the DOT governing the reverse logistics process.

Big Changes Ahead for OSHA’s HazCom Standard

Andrew Brought discusses an update on OSHA’s Hazard Communication Standard (HazCom), 29 CFR 1910.1200,and its significant facelift. By OSHA’s own estimate, over 5 million workplaces across the country will be affected by the revised regulations.

EPA Region 8 RMP Enforcement Directed At Water Treatment Plants and Facilities that Store and Use Anhydrous Ammonia

On July 26, 2012, four different companies settled alleged violations of EPA’s Risk Management Program (RMP) regulations under section 112(r) of the Clean Air Act, 40 CFR Part 68, which are designed to prevent and minimize chemical accidents involving extremely hazardous substances.

EPA Continues to Target Food Warehousing and Distribution for Clean Air Act 112(r) Enforcement

Businesses that use commercial refrigeration systems, such as cold storage, retail grocers, wholesale food distribution, and related warehousing and transportation companies, continue to face enforcement scrutiny from EPA regarding the use and storage of the refrigerant anhydrous ammonia. In particular, companies that store more than 10,000 lbs. of anhydrous ammonia are required to comply with EPA’s Risk Management Program (RMP) regulations under the Clean Air Act Section 112(r), 40 CFR Part 68.

Environmental Permit Appeals in Missouri Subject to New Process

Effective August 28, 2012, businesses and companies subject to environmental permits in the State of Missouri will be subject to new permit appeal procedures.

EPCRA Chemical Storage Reporting to Increase Under New EPA Regulation

Beginning January 1, 2014, businesses subject to EPA’s Tier I and Tier II EPCRA hazardous chemical storage inventory reporting requirements will be required to submit more detailed information as part of a new EPA final rule recently published in the Federal Register, 77 Fed. Reg. 41,300 (July 13, 2012).

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